McFarlane Baxter

McFarlane Baxter One-stop shop for all import and export related advice, services, and documentation.

🇬🇧 Your company sells technology for military and dual-use goods. Your sales people need to visit clients overseas. They...
16/04/2026

🇬🇧 Your company sells technology for military and dual-use goods. Your sales people need to visit clients overseas. They need to talk about your products, and maybe demonstrate their capabilities.

❓️ At what point does your activity cross the threshold to needing an export licence?

✋🏻 Marketing of an export-controlled product discloses controlled information at the point where technical data [beyond general, publicly available marketing descriptions] is shared with a foreign national, whether that sharing occurs abroad or within the UK.

Controlled disclosure occurs during marketing activities when providing:

➡️ detailed technical specifications, blueprints, or diagrams;

➡️ performance characteristics that reveal the item’s, software’s, or technology’s specific military or dual-use capabilities;

➡️ engineering know-how or technical support necessary for the “development”, “production”, or “use” of the item.

🤔 If you're unsure, speak to an expert.

📧 [email protected]
☎️ 0330 043 9349 | 07955 434 980

🌐 mcfarlanebaxter.com

💥 SPOILER ALERT! If you're a UK company that exports goods or services, HMRC and ECJU audits aren't entirely random 🤯➡️ ...
10/04/2026

💥 SPOILER ALERT! If you're a UK company that exports goods or services, HMRC and ECJU audits aren't entirely random 🤯

➡️ Most HMRC customs audits are triggered by specific patterns in declaration
data:

❌️ Incorrect commodity codes;
❌️ Preferential origin claims without supporting evidence;
❌️ Declared values that don't match invoices.

➡️ ECJU (Export Control Joint Unit) audits are not entirely random either, although they can sometimes seem that way. Broadly speaking, they are designed as a 3-yearly check on all companies holding export licences, but they are also driven by risk assessments and targeting.

✋🏻 Companies with high-risk ratings, frequent licence users, or those with previous compliance issues are more likely to be selected.

🚩 Previous compliance issues are amajor red flag because they often indicate deep-seated cultural, operational, or systemic failures rather than isolated incidents. Regulatory bodies, investors, and business partners view past violations as predictors of future risk, suggesting a higher likelihood of financial crimes, data breaches, or legal failures.

🤔 Maybe save yourself the headache not if, but when you get audited. Speak to an expert.

📧 [email protected]
☎️ 0330 043 9349 | 07955 434 980

🌐 mcfarlanebaxter.com

🇬🇧 The UK’s defence sector is seeing a notable shift, with more SMEs stepping into the global export market than ever be...
08/04/2026

🇬🇧 The UK’s defence sector is seeing a notable shift, with more SMEs stepping into the global export market than ever before.

✅️ Driven by innovation, agility, and niche capabilities, smaller firms are increasingly complementing the traditional primes, delivering cutting-edge solutions to international partners. From advanced manufacturing to cyber and AI, UK SMEs are proving they can compete, and win, on a global stage.

✋🏻 But with increasing geopolitical tensions, evolving sanctions regimes, and tighter scrutiny on dual-use technologies, the risk landscape has shifted significantly. Smaller organisations are no longer under the radar; in fact, they’re often more exposed due to limited internal compliance resources.

❌️ Failing to get export controls right can mean more than fines. It can lead to reputational damage, contract loss, and exclusion from critical supply chains. On the flip side, strong compliance builds trust with government and prime contractors, and can be a real differentiator in competitive bids.

✅️ We can audit your current capabilities and capacity in the area of export controls and compliance; we can put policy and procedure solutions in place to better manage your export compliance; and we can manage your exporting operation for you, or empower you do it yourself.

📧 [email protected]
☎️ 0330 043 9349 | 07955 434 980

🌐 mcfarlanebaxter.com

➡️ Export inspections and audits are increasing significantly, driven by intensified enforcement of customs compliance, ...
30/03/2026

➡️ Export inspections and audits are increasing significantly, driven by intensified enforcement of customs compliance, tighter border controls, and a focus on recovering unpaid taxes.

➡️ Authorities are focusing on misclassified goods, incorrect valuations, and improper use of preferential origins, with a particular rise in post- export/import audits by HMRC.

❌️ Dual-Use Goods: Inadequate awareness of controls on dual-use technology remains a major cause of breaches.

❌️ Documentation Failure: Non-compliance with license conditions and poor record- keeping are leading to increased investigations.

➡️ The Government is actively trying to recoup lost duties, taxes, and VAT. Five years after the EU exit, UK authorities are tightening control, with less leniency for errors in import/export declarations.

✅️ We can audit your current capabilities and capacities in the area of export controls and compliance; we can put policies and solutions in place to better manage your export procedures and compliance; and we can manage your exporting operation for you, or empower you do it yourself.

📧 [email protected]
☎️ 0330 043 9349 | 07955 434 980

🌐 mcfarlanebaxter.com

What a surreal couple of weeks it's been. Work feels like I'm living out the story from a Tom Clancy book.The rapidly ev...
12/03/2026

What a surreal couple of weeks it's been. Work feels like I'm living out the story from a Tom Clancy book.

The rapidly evolving crisis in Iran is another reminder that drones are now central to modern security.

As threats to shipping lanes and critical infrastructure grow, the ability to responsibly scale and export defensive technologies has never been more important.

I support clients navigating controlled exports, helping ensure sensitive technologies move across borders compliantly, and reach trusted partners who need them.

Behind the scenes at Liverpool John Lennon Airport yesterday, we learnt that some people think it's okay to carry a bric...
04/03/2026

Behind the scenes at Liverpool John Lennon Airport yesterday, we learnt that some people think it's okay to carry a brickie's trowel, a carpenter's awl, or a massive great wrench through security in their hand luggage!

This perhaps goes some way towards explaining why my oracle-level expertise and general amazingness are lost on some folks when I try to impress the importance of export controls for dual-use or military goods ...

It's probably the same people who think you can get on a plane with a hammer and a hunting knife! 🤦🏼‍♂️

On a more positive note, the Airport Fire Station, with all its boys' toys, is absolutely awesome! 😎

West Cheshire and North Wales Chamber of Commerce

Many people think “exports” only mean shipping physical goods overseas. In reality, it can be much broader than that.If ...
02/03/2026

Many people think “exports” only mean shipping physical goods overseas. In reality, it can be much broader than that.

If an employee takes a company laptop abroad, accesses company servers from another country, or remotely views controlled technical data, that can be classed as an export under export control rules.

In sectors like aerospace and defence, data matters just as much as hardware. Drawings, software, specifications, and know-how don’t need to be physically shipped to cross a border.

This is why policies, training, and permissions matter; and why legal guidance is so important.

Exports aren’t always boxes and pallets. Sometimes, they’re just a login away.

If you're unsure whether your overseas activity is regulated, speak to an expert.

📧 [email protected]
☎️ 0330 043 9349 | 07955 434 980

🌐 mcfarlanebaxter.com

A company director has been jailed for attempting to export military‑grade night vision rifle sights without the require...
23/02/2026

A company director has been jailed for attempting to export military‑grade night vision rifle sights without the required licence.

https://www.gov.uk/government/publications/notice-to-exporters-202603-director-jailed-for-illegal-export/nte-202603-company-director-jailed-for-illegal-export

Steven Gates, 47, from Wakefield, attempted to export the goods, classified as ML1d under the UK Military List.

He misdescribed the items as “low‑value cameras” to conceal their controlled status.

Even if you're doing your best to be compliant, the system isn't always easy to navigate, and can be a full-time job in itself.

The consequences for getting it wrong can be severe, career-destroying, and life-changing.

If you're importing or exporting anything at all, it pays to get it right first time.

Speak to an expert ➡️

📧 [email protected]
☎️ 0330 043 9349 | 07955 434 980

🌐 mcfarlanebaxter.com

"My broker handles compliance"Oh dear 🤦🏼‍♂️That's one of the most common and most dangerous assumptions in international...
19/02/2026

"My broker handles compliance"

Oh dear 🤦🏼‍♂️

That's one of the most common and most dangerous assumptions in international trade.

Good freight forwarders move the shipment; good customs brokers execute declarations based on instructions, and agreed SOPs.

❌️ They don't decide whether an export licence is required.
❌️ They don't assess product risk.
❌️ They don't classify HS codes.
❌️ They don't agree Incoterms.

➡️ Importers and exporters are legally responsible for their own sipments. Always.

Before delegating away compliance responsibility to someone who's job it isn't, maybe speak to an expert.

📧 [email protected]
☎️ 0330 043 9349 | 07955 434 980

🌐 mcfarlanebaxter.com

Export controls are far more than just shipping regulations; they are a complex, often invisible, layer of international...
10/02/2026

Export controls are far more than just shipping regulations; they are a complex, often invisible, layer of international law that affects technology, research, and business daily.

Here are some of the most interesting and critical aspects of export controls:

▶️ "Deemed Exports" (Sharing Knowledge is Exporting): An export does not have to be a physical box crossing a border. Disclosing, transferring, or even allowing a foreign national (even a student or employee) to access controlled technology or technical data within your own country is considered a "deemed export" to that person’s home country.

▶️ Catch-All Controls: Even if an item is not explicitly listed on a government control list, it may still require a license if you know or suspect it will be used for military, nuclear, or human rights violations. This "catch-all" control means you are responsible for knowing the final end-use of your technology.

▶️ Extraterritoriality (US Long Arm): US export controls (such as EAR or ITAR) often follow US-origin items, components, or technology even after they have left the US. If a product made in Europe contains more than a certain percentage of US-origin content, it may be subject to US restrictions.

▶️ "Dual-Use" Confusion: Many controlled items are not weapons. They are "dual-use," meaning they have a commercial purpose but can be repurposed for military use. Examples include specialised machine tools, encryption software, advanced semiconductors, and even high-strength materials.

▶️ Encryption and Software: Sending a file containing controlled data via email, hosting it on a cloud server accessible from abroad, or providing software-as-a-service (SaaS) can be classified as an export of technology.

▶️ Criminal Liability for Academics: Export control legislation applies to academic research and teaching, not just commercial trade. A principal investigator (PI) can face personal criminal liability and severe penalties for transferring technical data to foreign collaborators without a licence.

📧 [email protected]
☎️ 0330 043 9349 | 07955 434 980

🌐 mcfarlanebaxter.com

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